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Company: EY Frank Hirth
Location: London, England
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Average client size: £5 million - £25 million
Fixed fee offering: Yes - Where the scale of the project is clear and it is an area previously dealt with then we would be open to agreeing fixed fee arrangement looking to balance interests of both parties. Compliance work is very often completed under fixed fee terms.
Number of offices globally: 1-5
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Client work includes:
- Advised very senior non-domiciled banking executive on tax planning prior to moving to the US. This covered advice for both Federal and State purposes and included review of family trusts, international pension plans and the use of deferred variable annuities. Despite moving to NY, the client’s level of taxation while there is expected to be lower than when living in the UK.
- I helped very wealthy client become compliant with their US taxes through entering them into an offshore voluntary disclosure program. I then helped the client surrender their US citizenship. I assisted the client at all stages of this process from booking the interview and completing disclosure forms to undertaking advanced preliminary tax planning to avoid the impact of covered expatriate status. The client successfully extricated themselves from the US tax net with minimal taxes and no penalties.
- When a major US private equity firm was looking to go through an Initial Public Offering I led the advice on the UK and US personal and employment tax issues arising from the proposed restructuring steps. Ultimately ensuring that no employees incurred double tax or dry tax charges.
- Advised US founder of UK based private equity firm on the impact of both the new Disguised Investment Management Fee and the Income based carried interest rules. Based on my advice the client engaged leading UK law firm and the client restructured their fund agreements to avoid these rules from applying.
- Advised wealthy UHNW client and their family on the impact of the April 2017 deemed domiciled changes. This involved engaging Queen’s Counsel to help review complex US trust arrangements and the applicability of the ‘Anson LLC decision’. I helped the client put in place planning strategy designed to avoid double taxation in US and UK and ensure optimised tax position. The client’s overall worldwide tax liability is now not expected to increase significantly despite the loss of the remittance basis.